Former Madagascan President Marc Ravalomanana must be cursing the Southern Africa Litigation Centre (SALC). Until SALC's precedent-setting High Court victory earlier this year in the Zimbabwe torture case, Ravalomanana was happily living in exile in South Africa waiting for his chance to return home. But now he finds himself under investigation by his host's National Prosecuting Authority (NPA) for alleged crimes against humanity while he was battling to stay in power in Antananarivo.